spain flag

GloBE Country Guide: Spain

Summary

Status Enacted Law and Regulations
LawOrder HAC/1198/2025, dated 21 October and published 29 October 2025, approved the final Forms 240 (constituent-entity filer notification), 241 (information return) and 242 (self-assessment). The approved forms supersede the June 2025 drafts noted below. Current order and amendments.

On March 17, 2026, Spain’s Navarra region published Decree 13/2026, of February 25, 2026 in its Official Gazette. This approves the Global Minimum Tax Regulations for the Navarra Region and applies to tax periods beginning on or after December 31, 2023.

On June 3, 2025, Spain issued the draft Pillar 2 forms for public consultation. This includes Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).

On April 29, 2025, Spain published Law No. 3/2025 of April 29, 2025 in the Official Gazette, which modifies the Economic Agreement with the Basque Country to adapt the agreement to Law No. 7/2024 of 20 December 2024 for the implementation of the Pillar 2 global minimum tax.

On April 2, 2025, Spain issued Royal Decree 252/2025 to approve the Regulations for the Global Minimum Tax. The Regulations include a number of aspects of the OECD Administrative Guidance. 

On December 21, 2024, Spain published law 7/2024 in its Official Gazette to transpose the EU Minimum Tax Directive. This includes an IIR and QDMTT from December 31, 2023 and the UTPR from December 31, 2024.

On December 19, 2024, Spain’s Parliament approved the law to transpose the EU Minimum Tax Directive.

On December 19, 2023, Spain’s Council of Ministers approved a draft law to implement the EU Minimum Tax Directive. It was subject to a consultation and was then subsequently approved as a second draft by the Council of Ministers on June 4, 2024. On June 14, 2024, the Official Gazette of the Spanish Parliament published the text of the Bill.

Draft GMT Regulations of December 4, 2024
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesForm 240 notification: before the last day of month 12 after year-end (30 December for an ordinary calendar-year group), or before the last day of month 15 on first entry into scope. Form 241: month 15, within the two months preceding the last day of month 18 for the transition period. Form 242 filing/payment: 25 calendar days after month 15, or month 18 for the transition period. Special first-year and foral rules apply. Current Order HAC/1198/2025; AEAT Form 240 instructions.
Safe HarboursYes – Transitional CbCR Safe Harbour, Transitional UTPR Safe Harbour, QDMTT Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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